This Privacy
Policy applies to the following Web site: (“Site” or
“we/our”).

At Grooby we are totally committed to protecting your privacy and security.

The following information is designed to help you understand how we
collect, use, disseminate and safeguard the information you provide
to us while accessing and using our Site. By accessing and using our
Site, you signify your assent to this GDPR policy. If you do not
agree with our information practices, please do not access or use our
Site. As provided below, we reserve the right, at our discretion, to
change, add or remove portions of this policy at any time by posting
such changes to this page. Such changes will be effective upon
posting. The Site requests that you read this GDPR policy
carefully and consult it regularly.

Information
Collection and Use

A. Information Collection.

We are the owner of the information collected on the Site. When users
order our services, we collect information such as name, address,
email address, IP address, user name, and password. We may collect
information from our users when the user signs on to our home page,
enters account information, and otherwise uses/orders/purchases our
services. Information is collected through completion of on-line
forms, mail-in forms, and membership applications and/or sent to our
payment processor for credit card verification. If a user refuses to
provide the required information for a specific service, the user
will not be able to utilize that service.

B. Information Use.

We use information for the following purposes: to fulfill your
requests for products and services, and to contact you. We also use
your information for market research data purposes to increase the
user’s experience according to personal interests. We reserve
the right to formulate statistical models to accomplish the Site’s
goals through surveys or contests.

Registration and Order Forms

To use, purchase, or order services on our Site, a user must complete an on-line form. The
form requires a user to provide us with certain contact information.
This information is used to purchase products and services, manage
the user’s account, and/or ship products. If we have trouble
processing an order or otherwise need to contact a user, the contact
information is used to get in touch with the user. From time to time,
we may also ask that you provide us with additional information so
that we can better tailor our services to meet your needs.

Cookies

A cookie is a piece of data stored on the user’s hard drive when the user visits
certain Web sites and contains information about the user. We will
not use cookies to collect personal identification information from
our users. However, we will use cookies internally for purposes of
providing additional personalized services to our users. For example,
we may use cookies to determine whether the user completed the join
form, to tell us if the user's browser accepts cookies, to inform us
when the user has successfully logged in, to determine if the user is
using the auto-login feature, to store the user’s favorites
list, and to determine whether the user has seen the Site’s
pop-up from the promotional pages. Please note that some of our
business partners may also use cookies on our Site (for example,
advertisers). However, we have no access to or control over these
cookies.

Sharing and Third Party Distribution of Information

We do not sell or share, or otherwise make available, personally identifiable information
about our users to third parties, other than billing companies who are directly related to
your purchase or for the general operation of our sites. We also reserve the right to make
such information available to third parties in the future in order to enhance and personalize
our services, or in the case of bankruptcy, sale of an asset, business or division, a merger
or acquisition, or similar change of ownership. The Site also makes chat rooms, forums, message
boards, live video chat rooms, clubs, and/or news groups available to our users. Please remember
that information disclosed in these areas becomes public information and you should exercise
caution when deciding to disclose your personal information.

Law Enforcement

We will cooperate with law enforcement authorities, private-party litigants, and others
seeking information about our end users to the extent required by
applicable law. Examples of such cooperation include compliance with
discovery requests, subpoenas, court orders and writs.

Links

The Site may contain links to other sites. Please be aware that we are not responsible for
the privacy practices of such other sites. We encourage our users to
be aware that when they leave our Site they should read the privacy
statements of each and every site that collects personally
identifiable information.

Security

We agree to use commercially reasonable efforts to protect the information you have
provided to us from unauthorized access by using encryption and other
security measures. Although we take reasonable efforts to make our
network secure, the Site cannot guarantee that the security measures
in place will stop third-party “hackers” from illegally
accessing your information. We encourage you to contact us if you are
interested in learning more about our security measures.

Children

Our Site is not intended for children under the age of 18 or 21, depending on the age
of majority in your jurisdiction. Our Site does not target children,
nor do we solicit data, or knowingly collect personally identifiable
information from them. We encourage parents and legal guardians to
spend time online with their children and to participate in the
interactive activities offered on the sites their children visit.

Data Quality, Access, and Updating Personal Information

The Site will take reasonable steps to ensure that the Site’s information and data
is complete, accurate, and timely for the user’s desired
purposes. If a user’s personally identifiable information
changes (such as email address), is inaccurate, or if a user no
longer desires our services, the user should contact us to correct or
update the information.

Information Retention

We retain all user information indefinitely.

Designated Data Protection Officer (DPO)

Our designated GDPR Officer who is based in the EU may be contacted via the following email address - admin@grooby.com

Newsletters, Correspondence, Opt-out and Data Removal Policy

We may send our users e-mails or other notices regarding new services, promotions, or
other information that may be of general interest. Users who no
longer wish to receive materials from us may opt-out of receiving
these communications by contacting us. You may also request complete removal of any data
we hold about you. We will comply will all requests for removal. Please email admin@grooby.com
with any opt-out or data removal requests.

How you can access and update your information

The accuracy of your information is important to us. We're working on ways to make it easier
for you to review and correct the information that we hold about you. In the meantime, if you
change email address, or any of the other information we hold is inaccurate or out of date,
please email us at: admin@grooby.com

You have the right to ask for a copy of the information Grooby hold about you
(we may charge 20EUR for information requests) to cover our costs in providing you with details
of the information we hold about you.

Notification of Changes

We reserve the rightto modify this GDPR policy at any time by posting such changes on
our Site. Any changes to this GDPR policy will become effective
upon posting such changes. If you access or use our Site, you
are required to periodically check our GDPR policy for any
changes. If you continue to access or use our Site after we have
changed our GDPR policy, you manifest your assent to the changes
to our GDPR policy.

If we decide to use your personally identifiable information in a manner materially
different from that stated in the GDPR policy at the time that
such information was collected, we will attempt to notify you of such
changes. You agree that if we send you an e-mail to the e-mail
address reflected in our records, such e-mail will constitute
acceptable notice to you of the change in our policy. The notice will
provide you with an opportunity to “opt-out” so that we
may not use your personally identifiable information in a manner
which is different from the manner described at the time that you
provided us with such information. If you do not affirmatively
“opt-out” pursuant to the instructions provided to you in
the notice, then you agree that we may use your personally
identifiable information in the manner described in the notice. (If
we have no e-mail address for you, or if we do not have a current
e-mail address for you, then you agree that adequate notice of the
change in our policy will be effected by posting such a change onto
our GDPR policy, which shall also disclose information about how
you may “opt-out” so that we may not use your personally
identifiable information in a manner which is materially different
from the manner described at the time that you provided us with such
information. If you do not affirmatively “opt-out”
pursuant to the instructions posted within the time period specified,
then you agree that we may use your personally identifiable
information as described in the posted notice).

Contact Information

If you have any questions about this GDPR Policy, you can contact us by sending an
e-mail. Please provide us with your name and e-mail address so we can
service you quicker.